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Representation on
Proposed Residential Redevelopment of former Glassworks
at Cardigan Road, Leeds LS6 1LF
Application Number 07/07439/FU

1 Leeds HMO Lobby is an association of associations, a coalition of some two-dozen local community groups in & around Headingley, concerned in particular with the impact on their communities of concentrations of houses in multiple occupation (HMOs), and more generally with the consequent demographic imbalance of the neighbourhood. This latter concern motivates the Lobby's response to the Planning Statement in support of the application for planning permission by Parklane Properties for a proposed residential redevelopment of the former Glassworks on Cardigan Road in Leeds.

2 Leeds HMO Lobby endorses many of the points submitted in the Planning Statement, in particular the desirability of using the site for housing. The Statement outlines some (not all) of the relevant planning policies (Section 3), it makes an evaluation of the application against the policies cited (Section 4), and it provides a sustainability assessment (Section 5). However, the Lobby cannot concur with the conclusion in Para 5.10, that "the development will be wholly in accordance with the stated aim of PPS1." On the one hand, the application is in conflict with policies not cited in the Statement, and on the other, it is not in conformity with those which are cited. Hence, on behalf of its member organisations (and thereby their individual resident members), Leeds HMO Lobby opposes Application Number 07/07439/FU by Parklane Properties.

3 The essential context within which any planning application must be evaluated is the neighbourhood within which it is situated. In the Planning Statement, only two paragraphs consider the site and situation of the Glassworks (paras 2.1 and 4.1), and these provide only a most rudimentary description. They make no reference to the over-riding characteristic of the area, which is polarisation - or demographic imbalance. The area is unbalanced in terms of tenure: 60% of households in Headingley Ward were privately rented in 2001 (Census). The majority of households are in multiple occupation: nearly 2,500 HMO licences have been issued in Leeds, nearly all in & around Headingley (and this excludes non-licensable HMOs). The area is demographically unbalanced: 61% were students in 2001; hence, 58% of the population was aged 20-29 (Headingley Ward, Census 2001). This also meant that the same proportion was transient, and the same proportion was seasonal. The Glassworks in fact lies within the most polarised area, the quadrangle bounded by the Harrogate Railway, Royal Park Road, Woodhouse Moor and Victoria Road, with extensions up Headingley Hill (Manors & Richmonds) and down Cardigan Road (to the Glassworks) - here, all 72 streets have a majority of students, and overall, students outnumber residents by two-to-one (Census 2001). The imbalance makes the area literally unsustainable - while the norm for schoolchildren is 20%, here it is only 7%. At this level, it is impossible for the community to renew itself naturally.

4 National and local planning policies recognise the significance of imbalance.
4.1 The Planning Statement quotes para 5 of PPS1 Delivering Sustainable Development, but fails to recognise its full significance: planning should promote sustainable development by "ensuring that development supports existing communities and contributes to the creation of safe, sustainable, liveable and mixed communities with good access to jobs and key services for all members of the community." The point is reinforced in para 16 (not quoted): "Development plans should promote development that creates socially inclusive communities, including suitable mixes of housing. Plan policies should ensure that the impact of development on the social fabric of communities is considered and taken into account" [emphases added].
4.2 Again, the Planning Statement quotes from PPS3 Housing, for instance paras 9 and 10: the aim is "To create sustainable, inclusive, mixed communities in all areas ... [and] ... A mix of housing ... to support a wide variety of households in all areas" [emphasis added]. However, the Statement entirely omits reference to the whole section on 'Achieving a mix of housing', comprising paras 20-24.

5 National planning policies are echoed in Leeds' Unitary Development Plan Revised 2006 (UDPR). The section on 'Student Housing' states: "the population overall is out of balance and action is needed to ensure a sustainable community [7.6.28] ... [Problems] are particularly associated with a high concentration of student occupancy, and planning has an important role in reducing and managing them through working to ensure that the community as a whole is well balanced and sustainable for the long term [7.6.29] ... the overall objective will be to achieve a more mixed population which is inclusive and sustainable [7.6.30] ... the Council will use its development control powers to manage provision of additional student housing as far as possible so as to maintain a diverse housing stock that will cater for all sectors of the population including families [7.6.31]."

6 In the light of local circumstances on the one hand, and of national & local policies on the other, it would seem evident that the last thing needed on the Glassworks site is an increase in polarisation and a diminution of community mix. Yet this is exactly what is proposed - more renting, more multi-occupancy, more students. The proposal is contrary to policy on mixed communities.

7 Local planning policy also refers to purpose-built development for students. The application is such a development, but the Planning Statement does not refer to the relevant UDPR policies.
7.1 Para 7.6.31 of the UDPR indicates that purpose-built development may be considered within the Area of Housing Mix - on three conditions. These are that they "will improve the total stock of student accommodation, relieve pressure on conventional housing and assist in regenerating areas in decline or at risk of decline." The application meets none of these criteria. For the first, see para 14 below, and for the second, para 10 below. With regard to the last, the neighbourhood is indeed an 'area in decline' (see para 8 below). But the reason for decline is precisely the demographic imbalance - which would be exacerbated by the proposed development.
7.2 Meanwhile, Policy H15A of the UDPR states: "THE COUNCIL WILL WORK WITH THE UNIVERSITIES AND WITH ACCOMMODATION PROVIDERS TO PROMOTE STUDENT HOUSING DEVELOPMENTS IN OTHER AREAS." The purpose of this policy is of course to divert student demand away from high-demand areas like Hyde Park, and towards other, low-demand areas, in order to restore balance. Purpose-built development in high-demand areas (like the present application) will of course compete with developments elsewhere, outside the Area of Housing Mix - and if permitted, will undermine their viability, and hence the whole thrust of local; policy.

8 Local policies and national policies are very explicit in resisting unbalanced communities. The reason is to be found, not only in their long-term unsustainability, but also in the immediate deterioration of local amenity. This is especially the case in & around Headingley, in direct consequence of demographic imbalance. This is evident locally in terms of crime, squalor and a 'resort economy'. The Safer Leeds partnership has identified six burglary hotspots in Leeds: the Headingley/Hyde Park hotspot is larger than all the other five put together (it exists because student houses offer soft targets and rich pickings). Headingley has been identified by Encams as the filthiest ward in the city (hence the [failed] experiment with Headingley Streetscene), and it has the worst recycling rate (8% compared with the city average of 24%). The local economy has followed the demands of the demographic polarisation: there are over sixty property agencies in the Area of Housing Mix, the city's only 24-hour licence is a few hundred yards up the road at the Cardigan Road Co-op, and take-aways have proliferated. In consequence, the suburb is now the most regulated in the city: in addition to the Area of Housing Mix, it is subject to a Cumulative Impact Policy (on pubs and take-aways), to a Designated Public Places Order (on public drinking), to a Direction on Letting Boards, and a Flyer Control Zone has been introduced. Meanwhile, community engagement has collapsed - not indeed among the resident population, but as a consequence of the dominance by the transient population. At the last local election, Headingley Ward had the worst turnout in the city, the only ward which fell below 20%.

9 There are good reasons therefore for the adoption by the UDPR of Policy H15, which states that "WITHIN THE AREA OF HOUSING MIX PLANNING PERMISSION WILL BE GRANTED FOR HOUSING INTENDED FOR OCCUPATION BY STUDENTS, OR FOR THE ALTERATION, EXTENSION OR REDEVELOPMENT OF ACCOMMODATION CURRENTLY SO OCCUPIED," only on the basis of five conditions. The Planning Statement argues (para 4.6) that the application meets all these criteria. Leeds HMO Lobby considers that it does not.

10 The first condition of Policy H15 is that "THE STOCK OF HOUSING ACCOMMODATION, INCLUDING THAT AVAILABLE FOR FAMILY OCCUPATION, WOULD NOT BE UNACCEPTABLY REDUCED IN TERMS OF QUANTITY AND VARIETY." The Statement says, quite correctly, that strictly speaking there will be no loss - as the development replaces a factory.
10.1 Nevertheless, the development has implications for 'the stock available for family occupation.' These implications are not easy to predict. (a) The Statement (para 4.6.1) argues that "60 student flats here could lead to 60 traditional houses being returned onto the general housing market." This is indeed one possibility. (b) However, this is not the lesson of experience. The initial reason for the proliferation of student housing in Headingley was that it followed the lead set by the location of the University of Leeds' halls of residence in this area (from Devonshire Hall onwards). Students prefer familiar surroundings. Strikingly, the same sequence has followed Leeds Met's development of halls in new areas: both Kirkstall Brewery and Sugarwell Court have attracted satellite colonies to Bramley and to Meanwood respectively. The same is likely to happen around the Glassworks, already in one of the most popular locations for students. A new hall here may lead to increased pressure on remaining family housing, and further reduction in 'the stock available for family occupation.' (c) Parklane Properties has probably the largest portfolio of student houses in the area. If it really anticipated reduced demand, its argument would carry more weight if it was prepared to return some of this portfolio "from the letting market onto the general housing market."
10.2 Two further points should be made. (a) The fundamental problem in the area is demographic imbalance, rather than precisely where students are housed. At best, therefore, the development would leave this imbalance unchanged; at worst, it will exacerbate the imbalance. (b) The presence of a hall of residence filled with 250 students would be a major deterrent to families who might consider moving into the area.

11 The second condition of Policy H15 is that "THERE WOULD BE NO UNACCEPTABLE EFFECTS ON NEIGHBOURS' LIVING CONDITIONS INCLUDING THROUGH INCREASED ACTIVITY, OR NOISE AND DISTURBANCE, EITHER FROM THE PROPOSAL ITSELF OR COMBINED WITH EXISTING SIMILAR ACCOMMODATION." The Statement argues that there would be no significant effects, as there are no houses immediately adjoining the site (para 4.6.2). This overlooks the impact of 250 students on the wider neighbourhood: the result will be 'increased activity' by 250 more young people, unavoidably generating 'noise and disturbance', throughout the day and night, and throughout the week. The increased number of students in the area will also exacerbate the decline in amenity outlined in para 8 above. (Worryingly, no mention is made in the Statement of any plans for on-site management of what would be a de facto large hall of residence.)

12 The third condition of Policy H15 is that "THE SCALE AND CHARACTER OF THE PROPOSAL WOULD BE COMPATIBLE WITH THE SURROUNDING AREA." Any new building would be an improvement on the present factory eyesore. And the scale and character of the present proposal may well be "in line with extant planning permission" (Planning Statement, para 4.6.3). But this is not to say that it is compatible with the surrounding area. The five- and six-storey proposal is entirely out of scale with the surrounding terraces, which are predominantly two-storey, sometimes with a third roof-storey. And the materials and structure are entirely out of character with the brick-and-slate materials and the fenestration and roofing of the neighbouring terraces.

13 The fourth condition of Policy H15 is that "SATISFACTORY PROVISION WOULD BE MADE FOR CAR PARKING." Provision is made for barely 20% of the occupants - though parking guidelines suggest 25%. Contrary to para 4.6.4 of the Planning Statement, either of these figures is quite inadequate, resting as they do on out-moded assumptions about student resources. (It is worth noting that a quarter of Leeds University's students are from public schools.) A recent survey showed in fact that car-ownership in student houses was two-and-a-half times the city average (Ian Richardson, An Investigation into the Social Impacts of Students in Leeds, University of Leeds, 2005). The development is indeed relatively close to the University of Leeds, and it is served by public transport. But this ignores that fact that motorists (including students) use their cars as much for leisure purposes as for work. Excess cars brought to the site will simply add to the congestion of neighbouring streets.

14 The final condition of Policy H15 is that "THE PROPOSAL WOULD IMPROVE THE QUALITY OR VARIETY OF THE STOCK OF STUDENT HOUSING." Given that the area is saturated with student housing, it is difficult to see how the development would "broaden the range and choice of student housing locally" (Planning Statement, para 4.6.5). The area is already awash, both with HMO rooms and with purpose-built rooms. There is in fact an over-supply of student accommodation in Leeds. At its Owners' Briefing on 18 December 2007, Unipol Student Homes estimated a surplus of over 4,000 rooms in Leeds, in & around Headingley. The only way in which student housing might be diversified would be in other areas of the city, which could be both cheaper and safer for students.

15 Returning to national policy, again the application fails to meet the criteria claimed. For instance, para 5.10 of the Planning Statement says, "the development will be wholly in accord with the stated aim of PPS1 at paragraph 23 that LPAs should ensure the provision of sufficient, good quality, new homes … in suitable locations … The aim should be to ensure that everyone has the opportunity of a decent home." However the accommodation to be provided at the Glassworks is not homes as understood by most people. The accommodation is cluster flats, to be occupied by students on a temporary and seasonal basis. Indeed, such flats fall within DCLG's definition of a second home: privately-owned accommodation that is not occupied by anyone as their main residence [students of course go home in vacations] (DCLG, Survey of English Housing, 2007). These flats are in fact seasonal second homes for students, not primary homes at all. By providing second homes instead of first homes, the development is directly contrary to national planning policy.

16 Leeds HMO Lobby therefore draws three conclusions regarding Parklane Properties' application for residential redevelopment of the Glassworks.
16.1 The application is contrary to national and local policies on mixed communities (and also to local policies on purpose-built developments for students).
16.2 The application does not meet the criteria for housing intended for occupation by students specified in Policy H15 of the UDPR.
16.3 In fact, the application represents a missed opportunity. On the one hand, it provides for a market where there is already a surplus. On the other hand, it ignores the city's real need, which is for family housing. As para 5.10 of the Planning Statement notes, according to PPS1, "the aim should be to ensure that everyone has the opportunity of a decent home." Providing for students at this location fails to meet the needs of the local community in particular and of the city in general.

Dr Richard Tyler, Leeds HMO Lobby, January 2008

The planning application by Parklane Properties was considered by Plans Panel West of Leeds City Council on 21 February 2008, and refused. Parklane Properties appealed, and a Public Inquiry was held on 8-10 October 2008. Leeds HMO Lobby submitted Proof of Evidence to the Inquiry.

Leeds HMO Lobby
email: hmolobby@hotmail.com website: www.hmolobby.org.uk/leeds